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Strategic Development Plans in 4 City Regions
Local Authorities
Aberdeen City Council: This proposal is welcomed in principle. There is an urgent need to prepare such a Plan for the north east of Scotland, following the adoption of the two Local Plans. There will need to be considerable consultations between the Executive producing the second National Planning Framework and those preparing the Strategic Development Plan, as these will be going on simultaneously. It is, however, hoped that in the north east it may be possible to begin work on a new Strategic Plan in advance of the next National Planning Framework. Further information is required on how the joint arrangements for preparing such a plan may work.
Angus Council: Reservations and concerns previously highlighted have focused on democratic accountability issues associated with Strategic Development Plans (City Region Plans) and how to ensure individual Council's retain an appropriate level of control over decisions affecting land within their area in accordance with the subsidiarity principle. The White Paper goes some way toward addressing these concerns by confirming that each Council working jointly to prepare a Strategic Development Plan for the city region will be represented equally on the Strategic Development Planning Authority. It also indicates that "ultimate accountability and responsibility will lie with the individual Council's themselves". Angus Council has also previously questioned the need for a dedicated team of officers to service the Strategic Development Planning Authority. It is therefore disappointing that the White Paper continues to require the joint funding of dedicated planning staff. From an Angus perspective there continues to be significant reservations on this one size fits all approach drawn exclusively from experience and practice in West Scotland. It would be more appropriate if some flexibility could be applied in this matter which would recognise different circumstances arising in different City Regions and would enable some discretion as to how each planning team might operate. The proposal to replace Structure Plans with Strategic Development Plans, based on the main cities, raises issues in relation to the roll forward and review of the Dundee and Angus Structure Plan. This plan became operative in October 2002 and it was anticipated that a review would have been undertaken around 2008.
City of Edinburgh Council: This addresses some concerns about the restrictive nature of the existing boundary of the Edinburgh and Lothians Structure Plan. The existing E& LSPJLC members have expressed concern that there should be some flexibility to allow strategic development planning authorities the freedom to include other councils where justified. This is particularly relevant in achieving co-terminous boundaries with transport strategy and economic development areas. Consequently, there is a need to permit flexibility for the constituent local authorities to define the city region boundary and to agree the most appropriate local arrangements for a support team. The Lothian model of flexible joint working must remain an option.
Dundee City Council: The Council has consistently supported changes to the current system of Strategic Planning in Scotland which it has held to be inappropriate and unsustainable. Dundee City Council has supported the 'city region' concept throughout the consultation exercises, however, has expressed reservations with regard to the necessity for a dedicated full time team to prepare City Region Plans. The Council supports the principle of equal representation on the proposed joint committee. The proposed strengthening of the National Planning Framework is welcomed which together with the preparation of City Region Plans ( CRPs) should provide adequate strategic guidance where it is required replacing the need for blanket coverage.
East Ayrshire Council: The loss of the current Ayrshire Structure Plan will have serious implications for the Plan team in terms of personnel, constitution and function. The Council continues to maintain its objection to this proposal. The legal status of the replacement Ayrshire Structure Plan will also require to be confirmed given that its time horizon is 2025.
East Dunbartonshire Council: This is already practice in East Dunbartonshire although the imposition of new procedures and particularly an SEA requirement will make this more challenging.
East Lothian Council: The status of the Strategic Development Planning Authority is unclear given the statement that "ultimate accountability and responsibility will lie with the individual councils....". Status will be important not just in preparing the Plan but in administering its implementation, for example will the SDPA have the right to call in applications for planning permission that it deems significant? The Edinburgh and Lothians Structure Plan was produced efficiently without the need for a permanent staff dedicated to that role, the proposals for administering and supporting the SDPA have the potential to be complex and expensive.
East Renfrewshire Council: Supported. However, it is important that the boundaries of the City Regions represent the sphere of influence of the cities, based on social and economic factors. Strategic retail matters must be included within the remit of SDPs. The programme for the preparation of LDPs should be synchronised with that of the SDP, with LDPs in step with but behind SDPs so they can reflect the strategic policies.
Fife Council: City Region-based strategic development planning, whilst raising issues of concern to Fife, represents a major opportunity for Fife Council to assert itself within the Edinburgh and Dundee City Regions. Proposed Regional Transport Partnerships should be aligned to support Strategic Development Plan areas, although this is generally supported, it is essential that Fife retains a Fife-wide approach to development planning
Glasgow City Council: The proposal is likely to involve little change for Glasgow and is supported in principle. Further clarification is sought, however, on the size of the geographic boundaries of the proposed Glasgow City Region and whether any significant change to the structure and method of preparing the City Region Plan is envisaged. The new arrangements are modelled largely on the current Glasgow and the Clyde Valley approach and there are likely to be opportunities for joint working between the City Regions, e.g. in respect of model policies, benchmarking, etc.
Highland Council: The Council resolved to express a more robust response to the Scottish Executive about the need for a Highland overview document which had full status as part of the development plan. Further, they felt that at this stage that it was unclear how other policy documents might be handled and in particular they referred to fish farming framework plans, coastal zone management, renewable energy and indicative forestry strategy. In relation to all of these it was felt that there was a necessity for proper status to be given to a Highland overview before coming down to geographically specific areas within a Council with an area of one third of Scotland.
Inverclyde Council: This is on the whole sensible, insofar as resources are in short supply in many LAs and the two-tier development plan has clearly been a luxury, which many LAs could not afford. But, this is one of a number of essentially cosmetic proposals because the larger Local Development Plans ( e.g. Argyll & Bute and Highlands) will still require a strategic overview and a development strategy within which the local area can be planned.
Midlothian Council: A matter of some concern is the proposal that the joint working arrangements should replicate the arrangements used in Ayrshire and in Glasgow/Clyde Valley. The view expressed previously here was that the more flexible arrangements that have been used in the preparation of the Edinburgh and the Lothians Structure Plan have proved satisfactory and could have been followed If equal representation on Joint Committees is to be accompanied by equal funding (as opposed to funding based on population), then it would be expected that there will be additional Government support to assist smaller authorities such as Midlothian. It is understood that the proposed arrangements for strategic development planning are not to include call-in powers. This should be explicitly stated. The White Paper states (page 67) that, ideally, the preparation of strategic development plans will take place in parallel with the local development plans. This comment is at odds with the statement (page 27) that, in city regions, the local development plan will be required to comply with the strategic development plan, in other words that the processes are sequential. This should be clarified.
North Ayrshire Council (Chief Executive): This reasserts the Executive's position that areas other than the four largest city regions need only be subject to a single tier of development plan. This will have serious implications for the current Ayrshire Joint Structure Plan in terms of its constitution, function and personnel. North Ayrshire is the subject of strong and developing links with the Glasgow City Region in terms of housing demand, work and transport which will have an increasing influence on the proper planning of North Ayrshire and need to be properly reflected in the City Region's strategic statutory planning process. The legal status of the Replacement Ayrshire Joint Structure Plan which has a time horizon extending to 2025 will require clarification. The Council, through the Ayrshire Joint Structure Plan and Transportation Committee has previously objected to loss of a Strategic Plan for Ayrshire and would wish to maintain the position that resources and mechanisms must be retained to sustain the strategic interests of the Ayrshire Councils. Proper provision must be made to ensure North Ayrshire's appropriate engagement in the Glasgow City Region Structure Plan. The appropriate legislative provision must be made to ensure that there is no policy vacuum in either content or time frame when implementing the single tier approach.
North Lanarkshire Council: The model for City Regional Plans is basically the one currently operating effectively within Glasgow and the Clyde Valley, and would not therefore require any fundamental change to the present arrangement in this area.
Perth & Kinross Council: In previous consultations, the Council expressed its concern that Perth and Kinross would no longer be a Structure Plan authority; the Executive seem to suggest that strategic planning issues only exist in the four largest cities and that there are no strategic issues faced by other parts of Scotland. The Council is also of the view that the Dundee City Region Plan should not extend far into Perth and Kinross and the issues and overall volume of work associated with the development and implementation of that Plan are unlikely to be similar to that of the Glasgow and Clyde Valley Plan. It is suggested that Ministers are encouraged not to be overly prescriptive in determining the format and working arrangements of the SDPA and that the requirement for a dedicated planning team is unnecessary in the Dundee City Region context as a plan could be produced by joint working or secondment. The commitment to allowing the boundaries to be determined by the new Authority in conjunction with the constituent Councils is to be welcomed. Given that Perth and Kinross is likely to be a minor part of the Dundee City Region Plan, the Council considers a weighted approach to representation on the SDPA and on cost sharing, based on population and geographical area. The issues currently considered in the Perth & Kinross Structure Plan ( e.g. housing and business land supply) will still require a Council wide overview to be prepared and as a result this will only produce some minor savings in term of the publication of a separate document.
North Ayrshire Council: The Council, through the Ayrshire Joint Structure Plan and Transportation Committee has previously objected to loss of a Strategic Plan for Ayrshire and would wish to maintain the position that resources and mechanisms must be retained to sustain the strategic interests of the Ayrshire Councils. Proper provision must be made to ensure North Ayrshire's appropriate engagement in the Glasgow City Region Structure Plan. The appropriate legislative provision must be made to ensure that there is no policy vacuum in either content or time frame when implementing the single tier approach.
Renfrewshire Council: The Council has already commented on the proposal at previous consultation and accepts that the two tier development plan system will continue in the Glasgow and Clyde Valley area.
South Ayrshire Council: This Council, together with the other two Ayrshire Councils, have previously, through the Ayrshire Joint Structure Plan and Transportation Committee, submitted their concerns about this proposal to the Scottish Executive.
South Lanarkshire Council: It is noted that the proposed establishment of Strategic Development Planning Authorities closely follows the model currently used to deliver the Glasgow and the Clyde Valley Joint Structure Plan, which is viewed as 'best practice' which will be rolled out across the other 3 city regions. In this regard, it is welcomed recognition of the partnership work that this Council and other authorities have delivered.
West Dunbartonshire Council: The current working arrangements, involving the Joint Committee, equal financial contributions and equal voting rights are the procedures promoted in the White Paper for all four city regions. These arrangements already put considerable stress on the very limited staff resources of small authorities. Despite there being a dedicated core team staff there is a constant requirement for local authority officers to input time and information to topic groups and meetings at various levels. Removal of the consultative draft stage will help but staff resources will be stretched - particularly at EIP and PLI - to meet the requirements. The proposal to share the costs of EIPs is not acceptable. Small local authorities could not pay the costs of both public local enquiry and examination in public if they happened to coincide in the same financial year, which they might well do. It is suggested that this would be an opportunity to review the boundaries of the strategic development plan, for example to exclude the National Park and to include the Helensburgh area.
West Lothian Council: (1) The requirement for a permanent SDPA will have significant financial implications for West Lothian and will reduce the flexibility open to the authority to allocate varying levels of resource and expertise at different stages of the plan preparation process. The current arrangements for preparing the Edinburgh and the Lothians Structure Plan have proven successful and these should be carried forward when preparing strategic development plans. (2) Given the close relationship between transportation and planning, consideration should be given to matching the geographical area of the regional transport partnerships and the city region planning areas.(3) It is not clear how site specific the regional development plan will be and what, if any, call-in powers the strategic planning development authority will have. If it is deemed necessary to have a SDPA, West Lothian Council would be against the authority having call-in powers.(4) It is noted that there will be equal political representation on the planning authority. This is inconsistent with the voting arrangements on the regional transport partnerships which will lead to inconsistency of decision making. Also, given that each authority will have a minority representation on the authority, it will be important to ensure that the current provision for the submission of minority strategic development plans (structure plans) is retained. (5) Meeting the costs of SDPAs on an equal basis will significantly increase the costs for smaller authorities like West Lothian Council. If proposals to establish SDPAs are followed through, the increased cost for smaller authorities should be recognised.
Other LA Organisations
Edinburgh and The Lothians Structure Plan Joint Liaison Committee ( ELSPJLC): The replacement of structure plans and local plans with a new system of strategic and local development plans is generally supported. The requirement for new plans to be "shorter, targeted on spatial issues and.......focused on delivery and outcomes" is welcomed. However, there remain concerns about the geographical extent of the areas to be included within the strategic development plan. In the case of the Edinburgh CRP, there should be much greater consistency with the area covered by the proposed new Regional Transport Partnership. It makes little sense to manage strategic transportation on a different geographical basis from strategic land use planning. There may be merit in introducing some flexibility to allow SDPAs the freedom to include other councils where justified. While the ELSPJLC supports the creation of Strategic Development Planning Authorities, it believes that the respective roles and status of the SPDA and the individual councils is unclear. A clearer indication is needed as to whether decisions taken by the SDPA will be binding on individual councils, and if this authority will have the power of call-in. It is the ELSPJLC's view that such a power of call-in is not required and that the existing right of an individual council to submit alternative proposals in respect of particular matters should be continued. The ELSPJLC is of the view that the arrangements for a support team should be a matter for the constituent local authorities and that the more flexible joint working arrangements put in place for the preparation of the Edinburgh and The Lothians Structure Plan have proven merit and should be available as an option. These arrangements do not require a permanent, dedicated team; instead, staff can be assigned to structure plan work on a flexible basis, drawing on particular skills and expertise as and when required. Additional resources can be dedicated to the project at key stages. This flexibility will be lost if a permanent team is made a requirement. The ELSPJLC also has concerns that the maintenance of a dedicated team on an equal funding basis could weaken local political control and have significant resource implications, particularly for the smaller authorities.
Non Departmental Public Bodies
Highlands and Islands Enterprise: We recognise that planning issues are different in city regions and would require Strategic Development Plans. It is discomfiting, however, to read that there are four large city regions - the implication is either that the Inverness area is of insufficient scale or importance to count as a city region or that it is a small city region. This in a sense fails to recognise that while Inverness may be smaller than Dundee or Aberdeen, its relationship with its hinterland is of a comparable level of importance. In contributing to the growth of population in the
Highlands & Islands over the next twenty years or so, Inverness could grow from its current 65,000 to around 100,000 and beyond. There are clear strategic considerations for the rest of Scotland arising from that which, we believe, should be reflected in the NPF.
Historic Environment Council for Scotland: While HEACS recognises that the move to single tier status for development plans, except in the four city regions, will not necessarily impact extensively on measures to improve the management of the historic environment, it is worth recording that in moving to city regions the opportunity exists for more joined up government. With new boundaries proposed for Regional Transport Authorities (that do not seem to mesh with the city regions) and concern over Enterprise Company and Health Board boundaries, the opportunity should be taken to rationalise into a coherent whole. Nor should the change to single tier plans lead to a minimalist approach to the plans themselves.
Scottish Enterprise: This reflects proposed changes to Scottish Enterprise's own operating structure, in particular the development of Metropolitan regions. These Metropolitan regions reflect not a new administrative tier, but rather a more co-ordinated approach to the delivery of key projects.
Scottish Environment Protection Agency: Agree that a strategic tier is logical and necessary for the main urban centres and their hinterlands. SEPA has concerns about how this may operate in practice. For SEPA, there will be challenges in securing synergy between these new strategic planning areas and some of SEPA's planning units such as the Area Waste Plan areas and the future RBMP Advisory Group areas. For example, the current Structure Plan areas have a good synergy with the Waste Plan Areas as established by SEPA, the Executive and Planning Authorities as part of the National Waste Strategy ( NWS). While the NPF will address this issue in respect of the strategic framework, the new structure will require SEPA to work much harder to ensure that the new strategic and local development plans provide a suitable framework for delivering the NWS. It is not wholly clear from the White Paper if SDPs are intended to be site specific. This was suggested in previous consultations. SEPA considers that it would be useful if they were. We consider that plans which provide only a broad indication of sites provide a poor platform for consultation and SEPA finds it difficult to provide meaningful comments on broadly identified sites as we cannot give accurate information about potential environmental impacts/issues when site boundaries are not defined. Early identification of locations for such sites would enable a full evaluation of matters such as environmental impact at the earliest possible stage, thus permitting evaluation of alternatives and enabling more informed decision making. It would also aid assessment of the environmental effects of the plan as required under SEA. Defining the boundaries of the SDPs is clearly a very important step in their development. We would wish to see clear commitment that these boundaries will be subject to consultation so that those bodies with other planning processes, like SEPA, are afforded opportunity to input to these decisions. We would also wish to see as much synergy with existing "planning" areas such as waste or transport planning as possible in order to secure integrated approaches. In the past, SEPA has identified a number of strategic planning matters which it considers may occur outwith the city region areas and which require a strategic response. SEPA would wish to see that such issues continue to be effectively addressed through joined up working between planning authorities or through clear direction at national level in the NPF. Developments where this strategic view will be important include waste management facilities, renewable energy generation, communications, electricity transmission and public transport. SEPA considers it would be appropriate for the Scottish Executive to provide guidance for planning authorities in this regard.
The Theatres Trust: The proposals for a new two tier system of Strategic development Plans ( SDPs0 and Local development Plans ( LDPs) will give us a fresh opportunity to comment on the wording of such plans and ensure that there are policies for the protection and promotion of cultural facilities.
Other Public Bodies
Strathclyde Passenger Transport:SDPs will need to take account of and be informed by the Regional Transport Strategy ( RTS) for their area. We therefore trust that the Scottish Executive guidance on RTS and on SDPs will make clear that the respective role of RTS and SDP teams, including roles in advancing transport proposals and the hierarchy between transport strategies and development plans. There would be major advantages to both land-use and transport planning authorities if SDPs and Regional Transport Partnerships have identical boundaries with one another. Based on travel-to-work patterns, in the west of Scotland this would mean including Ayrshire, and the Cowal, Bute, Helensburgh, and the Lomond areas of Argyll & Bute Council with in the Glasgow based SDP.
The Development Industry
The Buchanan Partnership: The Buchanan Partnership is interested in the proposal for strategic development plans for the four largest city regions of Glasgow, Edinburgh, Aberdeen and Dundee. It is the Partnership's understanding that these strategic plans will be more streamlined than the existing Structure Plans and would welcome more information on this proposed change when available. If there is a clear distinction between the roles of the proposed strategic and local development plans, then this could lead to a more streamlined process, and greater efficiency. However, if there is any overlap in content, or policy conflict, then this will only consolidate problems of inefficiency, uncertainty and delay in the process, and the Partnership would oppose this.
Dawn Homes Limited: We look forward to the areas for the 4 City Regions strategic development plan being defined more closely before we can comment further. We are however disappointed that the Ayrshire model is too be disbanded despite being recommended as a model to 3 of the 4 city regions.
Elphinstone Land: We have concerns that, in areas of the country in which there will be no strategic development plans, the absence of strategic planning could have undesirable consequences. There is no recognition in the White Paper that even outwith the four major city regions, the demand for housing and other land is a cross boundary issue. Local development plans as proposed do not appear to have a strategic component to deal with these issue and could lead to planning authorities "diverting" demand to adjoining areas, with a consequential shortages. The Act needs to ensure that there is provision within to deal with such cross boundary issues. This could be done through and enhanced, and statutory National Planning Framework, which would indicate the general location of major housing release and would set area targets for housing completions, even in areas which will have SDPs.
Homes for Scotland: The critical element in a Strategic Development Plan, the successor to the Structure Plan, as far as housing is concerned is the forecasting of housing demand. No revised methodology has yet been published by the Executive that sets out how market information can be used. Both the Barker Report and the Minister confirm that there has to be more efficient forecasting not only of housing needs but a clearer recognition of market information. In our view, the methodology should take into account demographic factors, housing backlogs, market indicators, housing demand, affordability targets and an optimistic view of future economic expansion and the inward migration which it creates. Barker was very strongly of the view that this process should be carried out independently and free from political influence. Barker recommended that this work should be carried out at regional level. There is no such equivalent in Scotland. Also, Homes for Scotland does not believe that local authority planners have the appropriate training or skills to carry out this work. Ideally, independently employed economists should therefore carry out the work. Most of Scotland where the major problems lie will soon be covered by only four strategic development plans for the city regions. Homes for Scotland recommends that for each city region area independent economic consultants could be employed reporting to a stakeholder group comprising the local authorities, Scottish Enterprise, Communities Scotland and the private sector including house builders. This would have the twin advantage of producing a more realistic and objective answer and also of relieving the workload of planning and housing departments in local authorities. It is also likely to be quicker.
Manor Kingdom: The critical element in a Strategic Development Plan, the successor to the Structure Plan, as far as housing is concerned is the forecasting of housing demand. No revised methodology has yet been published by the Executive that sets out how market information can be used. Most of Scotland where the major problems lie will soon be covered by only four strategic development plans for the city regions. Manor Kingdom supports Homes for Scotland recommendation that for each city region area independent economic consultants could be employed reporting to a stakeholder group comprising the local authorities, Scottish Enterprise, Communities Scotland and the private sector including house builders. This would have the twin advantage of producing a more realistic and objective answer and also of relieving the workload of planning and housing departments in local authorities. It is also likely to be quicker.
Persimmon Homes: This proposal is welcomed given that it requires adjacent LAs to address their functions as hinterlands of the cities.
Scottish Retail Property Ltd: We strongly support the proposal in the White Paper to move towards a single tier of development plan over most of Scotland. However we are opposed to the proposal requiring strategic development plans to be prepared for the four main "city regions" in addition to local development plans. We fear that this proposal will just perpetuate the same problems that are associated with the present system of structure plans and local plans, namely extensive duplication, overlap and delay and the plans being constantly "out of kilter". The proposed mandatory examination of these plans when objections cannot be resolved could even make the process longer than at present. We believe that the strategic dimension of the development plans covering the four main cities in Scotland and their hinterlands could be informed by the commissioning of cross-boundary studies to determine proposals for strategic matters such as housing, shopping and transportation, without the need for the lengthy preparation and approval of a strategic plan. Along with the local development plan and an enhanced National Planning Framework, the strategic development plan will create in effect three levels of planning for the four city regions and in our view this is unnecessary overkill for such small areas. The associated proposal to set up four Strategic Development Planning Authorities similar to the Glasgow and the Clyde Valley model to prepare and monitor these plans will result in increased bureaucracy and be an unnecessary and unwanted burden on local government resources.
Stewart Milne Homes: Early input from stakeholders is required as to what constitutes a city region particularly when not all parts of Scotland may have the same City Region requirements. For example, it is our view that the City Region in the North East should be the Aberdeen Housing Market Area however a Housing Market Area may not be sufficient for a City Region in the Central Belt.
Other Businesses
Association of Electricity Producers: The proposal to introduce a single development plan is to be welcomed. It will provide a clearer reference point for all parties. However the challenge will be to combine local and structure plan policies into a coherent single plan.
Federation of Small Businesses: We welcome the move towards a single tier of development plan but in reality many planning authorities will still be subject to a structure plan in the form of new city strategic development plans. Care must be taken to ensure these plans remain purely strategic and do not duplicate local development plans.
Forth Ports PLC: Supports the underpinning objective for 'City Region' planning. However the White Paper fails to give the issue sufficient prominence, and the Planning Bill should clearly outline not only the appropriate boundaries, but also the form of decision making process that will be involved. Failure to clarify the scope, role and function of the Strategic Development Planning Authorities ( SDPAs) at an early stage will result in an inability to prioritise key projects. This could lead to insular decision making. It will be particularly important to ensure that City Region-wide policies area properly informed by accurate data, collated at the appropriate level. We note that the new Strategic Development Plans would mark a significant change in the style and purpose of plans at this level, setting out a clear vision and spatial strategy for development 5, 10 and 20 years ahead. We also note the requirement for authorities to work jointly to prepare these plans and the map page on 69 of the White Paper seeks to outline the boundaries of Strategic Development Planning Authorities ( SDPAs). We are unsure of the basis on which these boundaries have been prepared and would welcome the opportunity to contribute further to the debate on "City Region" planning, taking account of parallel recommendations coming forward from Scottish Enterprise on this issue. Forth Ports PLC question the position of the White Paper in relation to Fife which is unclear in the diagram, and would also query the position in relation to Falkirk and Clackmannanshire Councils. A key issue for the future of City Region planning will be the ability of SDPAs to make the difficult choices associated with focusing development in one location ahead of another. The Structure Plans prepared since reorganisation of Local Government in the early 1990s demonstrate this point, with dispersed development often prevailing. Within the Edinburgh City Region (whatever form that might eventually take) there is a need to focus development in key locations for the wider benefit of the City Region, and to underpin the implementation of essential infrastructure provision. This will require SDPAs to be led by a clear and unambiguous NPF in relation to the larger scale projects, and by SDPs which avoid spatial prioritising for reasons that are too often politically motivated.
Tesco Stores Ltd: We have previously supported the proposal for the four largest city regions producing strategic development plans, with a single development plan being produced by the other LPAs in the rest of Scotland. This approach should reduce unnecessary plan preparation.
Unison (Scotland|): Whilst a single tier of development plans is welcome these still require considerable cross boundary working even outwith the city regions.
UNITE Group plc: Advocates more joined up government, with key messages being delivered from central to regional and local government. Currently UNITE feel this isn't happening and even though we believe the proposals for city region scale planning go some way to establishing better reform we believe that there is a need for further clarity on the scope of city region plans and the proposed boundaries for city region areas. Further consultation on these issues is required.
Professional Organisations
Chartered Institute of Logistics and Transport: A particular aspect related to transport is that the areas for City/Region Strategic Development Plans differ from those selected for Regional Transport Partnerships. This could lead to confusion, additional bureaucracy, and possible conflicts. Care is required at this stage in developing the new arrangements to ensure future inter-action is efficient, cost effective and transparent. Liaison arrangements with the 'National Transport Agency' also need to be established at an early date for similar reasons.
RTPI Scotland: We support the proposals for City Region Plans. It is essential that any final decision on the strategic planning areas for city regions should have full regard for the need for an integrated approach to city regions overall I including economic development and transport issues) and that Ministers should ensure that they retain the right to reject the boundaries chosen by the appointed authorities for their city region strategic development plan, on these grounds.
SSDP: The Society feels the city region status is critical in providing a strategic planning framework but must emphasise the importance in the strategic connections with local authorities, which may not lie within that framework.
The Law Society of Scotland: The Society notes that the proposed abolition of the two tier development plan system in all but four city regions is now to be implemented. It notes that a two tier system will remain in the four city regions. The Society is concerned, however, that the White Paper does not fully explain the synergy between the two tiers. The Ministers have existing powers to direct action on the part of planning authorities and consideration should be given to directing planning authorities to complete particularly out of date development plans to avoid a further period of hiatus and delay until the new framework is clear and the new generation of plans has begun to be made. A major problem with the present two tier system is the difficulty of synchronising emerging local plans with dated structure plans. The Society notes with regret that the White Paper does not explain how the new arrangements will incorporate the new requirements for Strategic Environmental Assessment into the process. It is hoped that the arrangements for SEA assessment and the SEA gateway will be incorporated into the new system in a well co-ordinated manner. That SEA is being administered to some extent separately from the land use planning function of the Executive has resulted in some additional complexity in the plan making process. This should be addressed and measures taken towards co-ordination and the non proliferation of bureaucratic tests.
Planning Consultants, Architects and Lawyers
GVA Grimley LLP: Keen to engage in the debate on strategic development plan boundaries and their content at a later stage.
Paull & Williamsons: The proposals for change do not adequately address for the four city regions the problem of the synergy between the two tiers. A major difficulty with the present system is the inability to adopt a local plan which does not conform to an out-of-date structure plan. This problem may be overcome if the plans can be prepared concurrently and kept up-to-date; but there might be something to be said for allowing the adoption of a local development plan where a city region plan is substantially out-of-date.
Turley Associates: The White Paper's proposal to enhance the role of the National Planning Framework is supported, but in our view does not go far enough. There is a strong case that a more detailed NPF, with statutory force, could remove the need to introduce Strategic Development Plans for the City Regions. The aim should be to streamline the plan preparation process and not to add additional layers. The continuous rolling reviews of three separate plans for the City Regions will be too cumbersome, difficult to comprehend by the public, and an inefficient use of resources. Instead, the NPF is capable of undertaking the role of regional planning, providing broad locational guidance, which can then be applied in detail within Local Development Strategies. A similar two tier system is currently operating well in Northern Ireland, where the "Regional Development Strategy" ( RDS) provides a possible model for the NPF. The RDS is notable for its unambiguous spatial guidance and, in particular, the setting of specific targets for development ( e.g. housing requirements) and how this should be dispersed regionally and sub-regionally to create sustainable and balanced growth consistent with infrastructure provision. The current NPF, despite its good overall context setting, fails to provide adequate guidance in this regard.
Warren Consultants: The plans for the enhancement of the National Planning Framework suggested that it might become a "Structure Plan for Scotland" and it will certainly have this function in relation to local plans in areas which are not covered by the City Region Strategic-wide Development Plans. We begin to question whether the City Region Plans are necessary in such a small country as Scotland because they create in effect a third tier in the planning hierarchy (comprising NPF, the Strategic Development Plan and the Local Development Plan) and a three level hierarchy seems clumsy and unwieldy in a small country like Scotland. Having said all this, there is definitely a need for regional planning in Scotland, in particular because there are a number of "hot potato" planning issues which can only be addressed at regional level and for political reasons cannot be satisfactorily dealt with at local authority level.
Community Councils
Auchtermuchty & Strathmiglo Community Council: Strategic Development Plan - Constituent Authorities': The Plan on page 69 of the White Paper indicates Fife as being a part of the 'Strategic Development Plans' for both Edinburgh and Dundee. You will understand that we have a considerable concern as to how that might eventually impinge upon this sensitive group of villages and countryside lying at the western edge of Fife's East Area? The White Paper is not clear!
Currie Community Council: It appears to us that the proposed "strategic development plans" serve the same functions as the present Structure Plans. Will "Structure Plans" simply be renamed "Strategic Development Plans"? There may be financial benefits in reducing the number of Strategic Development Plans from 17 to 4 but the environmental consequences could be disastrous in a country that has such a varied landscape, especially as the plans relate only to highly populated urban areas where there is a "town-orientated" mentality. Surely the diagram should indicate the actual boundaries of the strategic development areas, and not the present authorities? How can we assess the area of influence of each authority otherwise? Why should the Kingdom of Fife come under the influence of Edinburgh and Dundee?
Helensburgh Community Council: The HCC supports retention of structure plans for the four city areas to provide cross-authority cohesion. There might be discussion (involvement) about the proposal that part of that cross-authority cohesion might be the inclusion of Helensburgh under the Glasgow and Clyde Valley Structure Plan. Helensburgh is substantially a dormitory and commuter town for Glasgow and for most of its wider services (transport, larger retail, health, tertiary education, entertainment, culture) it looks eastwards.
Knightswood North Templar Community Council: This community welcomes the provisions for structure plans in the four largest city regions, however we are disappointed that no strategic development plan is to be crated for the Highlands and Islands which is covered by a multitude of local development plans. Some strategic overview is undoubtedly required here. The requirement for the preparation of development plan schemes on a yearly basis is, again, another welcome addition.
Milngavie Community Council: The need for a Plan to cover the whole Clyde Valley as well as a Local Plan is important (p.69) particularly with regard to housing land and Green Belt.
Newburgh Community Council: We are totally opposed to the inclusion of rural areas in City Plans. We have nothing at all in common with Dundee.
West Garioch Community Council: The strategic planning process for rural areas should be retained in the new Bill.
Voluntary Organisations
Brethren Gospel Trusts: In the light of the adoption of Unitary Authorities, the retention of Structure and Local Plans appears to be unnecessary.
Built Environment Forum Scotland: Some frustration was expressed over the lack of rationale for strategic decision-making (for example on determining figures for housing allocation and spatial distribution) - and that survey work, which provides the base of information and framework for decision-making, is currently weak. Strategic decision-making must be transparent, and justifiable to all stakeholders.
Friends of the Earth Scotland: Strategic planning should be retained in some form outside the city-region areas, so as to ensure effective coordination on strategic issues.
Gatehouse Development Initiative: Getting rid of Structure plans and replacing them with Development Plans is just what we need.
General Trustees of the Church of Scotland: While the Trustees in general welcome this proposal, it seems to them that there is still scope for too much discrepancy in planning policy between different Local Authorities and they would push for the new system to include measures to ensure far greater uniformity in planning policy over the whole country.
Helensburgh Green Belt Group: The HGBG supports the intention to retain structure plans for the four city areas only and the emphasis on cross-authority cohesion. The HGBG suggests that consideration might be given to the possibility that such cross-authority cohesion might include parts of neighbouring (rural) authorities which are really part of the metropolitan areas.
Helensburgh Study Group: This has attractions since it saves time and money and enables inter-authority cohesion in the four main metropolitan areas. However, there could be problems. Since the Scottish Executive has the final say on Structure Plans at present it provides a safety net where an authority has been insensitive, incompetent or malign. It seems that this form of safety net is being removed for rural authorities. It appears that scrutiny will be provided in the proposed new system through a system by which the Scottish Executive Inquiry Reporters Unit ( SEIRU) examines unresolved objections to the LOP which appear to depend on local communities in fact (i) getting involved at the start and (ii) lodging objections at the consultation stage. It seems that part of the civic conscience role is being passed from government to local communities. The large city regions will have cross-boundary, inter-authority Structure Plans. The question arises as to whether those parts of rural authorities which are really integral to major conurbations should also be driven by the metropolitan structure plans.
Highland Perthshire Communities Partnership: The provisions for strategic development planning are misleading due to the lack of geographical clarity on what areas are to be covered by structure plans.
Portobello Campaign against the Superstore: The reliance on a plan based system does give more certainty to communities and developers alike although I believe that communities will have more difficulty in the consultation process for the strategic development plans in the four city states. Extra training of communities will be required to enable them to come to terms with some of the wider issues raised by these plans.
Rural Scotland: Rural Scotland considers that the current proposals for strategic development plans are poorly conceived and that there remains a need for a clear vision and tailored strategies for rural and remote areas.
Scottish Council for National Parks:SCNP does not accept that strategic planning is only required in the four largest city regions. Strategies for infrastructure, transport, minerals, waste disposal, energy etc are important in predominantly rural areas also. Similarly, there should be a strategy for National Parks, land based, marine and coastal, across Scotland.
Scottish Environment LINK: We welcome the fact that these will be subject to mandatory public examination but remain concerned about strategic planning for rural areas.
Scottish Wildlife Trust: This is welcome but there could be problems in certain areas if there is multiple development plan coverage without any overall framework for an area. In large rural areas problems could arise concerning the spatial planning of renewable energy developments or the provision major transport routes which cross individual plan boundaries.
The National Trust for Scotland: We remain concerned about the future of strategic planning for rural areas outwith the proposed strategic development plans for the four city regions.
Private Individuals
Anonymous: City Region Plans and Regional Rural Plans should involve all the affected local authorities and be chaired by the Scottish Executive. This will provide the link with the National Framework.
Bramley, E M Mrs: The White Paper talks of provision for Strategic Development -what does this really mean? Where are the clearly defined geographical boundaries for the proposed 'City regions?' It appears from the current wording to be more of a developer's charter than a stated intention to protect landscape or Green Belt.
Bryce, Ian: It is unclear how the envisaged strategic plans will impact upon areas such as Scotland's National Parks. The map of local authority overlaps disregards the present two Parks, with the Cairngorms National Park area included in two of the proposed "strategic development plan constituent authorities" areas and also outside these areas, in Highland Region.
Chilton, D&B: Since it is unclear which areas are to be covered by structure plans, the provisions for strategic development are open to more than one interpretation.
Sangster, Ann C Mrs: Exactly which areas are to be covered by structure plans is not made sufficiently clear. More detail on the map is required.
Smith, RL: The provisions for strategic development planning are lacking in clarity particularly geographical areas to be covered by the structure plans.
Politicians and Political Groups
Kennedy, Margaret Councillor: I have a number of reservations about the move to single tier Development Plans. In Fife the move from 3 Local Plans to City Region Plans is not a constructive way to deal with strategic issues affecting Fife only. The proposal contradicts the principles guiding the proposals set out at paragraph 5.3.3. A reduction in strategic development plans from 17 to 4 is far too drastic and will remove local accountability.
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